税收的公平时机

Edward J. McCaffery
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引用次数: 1

摘要

对基础广泛的税收制度的传统理解将所得税与各种形式的消费税进行了对比。单独的所得税就包括资本收益率;消费税则不然。简单的财务分析表明,在某些假设下,两种最常见的消费税——预付的,或基于工资的,和后付的,或销售税——是相等的,最重要的是包括模型中各时期之间的恒定税收和利率。再分配税的支持者坚持累进税率和收入基数,主要是对资本收益征税;反对者叫嚷着统一税率的消费税,经常引用密尔反对所得税对储蓄双重征税的著名论点来支持他们的观点。然而,一旦累进性被假定——正如其持久的大众吸引力所表明的那样——传统的理解就有缺陷了。问一个不同的时间问题,在纳税人的资金流动中,什么时候应该征收累进税?,让人们对税收制度有了新的认识。目前的税收制度是以工资为基础的繁重的税收制度。相比之下,累进现金流消费税在公平和适当的条件下,成为对资本收益率征税的最佳——最一致和原则性最强的税收。这为支持累进现金流消费税提供了进一步的理由,听起来与所得税支持者熟悉的理由一样。当资本交易(借贷、储蓄和投资)用于平顺一生内或一生之间(或纳税人)的劳动收益时,一致的累进现金流消费税将降低税收负担,而当资本交易用于增加一生内或一生之间(或纳税人)的劳动收益时,将增加税收负担。基于近一个世纪经验的批判性反思揭示了这样一种税收,即为有吸引力的规范理想提供形式。新的理解有助于表明,传统和最常见的消费税论据并不令人信服。征收消费税的最佳、最具吸引力的理由,既不是建立在简单的横向公平模型上,也不是建立在储蓄对个人或整体社会具有经济、结果主义重要性的主张上。更确切地说,是以约翰•罗尔斯(John Rawls)和其他自由主义理论家的方式,在社会契约主义意义上,主张合理设计消费税的是公平的主张——部分原因正是这种税有时(并非所有时候)会加重资本及其收益的负担,更主要的原因是,这种税指向了更大、更有意义的累进税制。对税收的新理解对税收政策和设计的紧迫实际问题产生了重要的见解,并为批评当代税收改革趋势打开了一个重要的窗口。税收政策之争不应像几个世纪以来那样,围绕所得税与消费税展开,而应围绕选择哪种消费税展开。如果不能正面解决这个问题,就会导致税收政策似乎不可避免地走向错误的选择,累进的、再分配的税收的命运悬而未定。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
The Fair Timing of Tax
The traditional understanding of broad-based tax systems contrasts an income tax with all forms of a consumption tax. The income tax, alone, includes the yield to capital in its base; consumption taxes do not. Simple financial analysis demonstrates the equivalence of the two most common classes of consumption taxation - prepaid, or wage-based, and postpaid, or sales taxes - under certain assumptions, most importantly including constant tax and interest rates between the periods in the model. Advocates of redistributive taxes insist on both progressive rates and an income base, in large part to tax the yield to capital; opponents clamor for flat-rate consumption taxes, often invoking Mill's celebrated argument against the income tax's double taxation of savings to support their case. Once progressivity is presumed, however - as its enduring popular appeal suggests it ought be - the traditional understanding is flawed. Asking a different timing question, when, in a taxpayer's flow of funds, ought progressive taxes be imposed?, casts tax systems in a new light. The present tax system emerges as an onerous wage-based one. A progressive cash-flow consumption tax, in contrast, emerges as the best - most consistent and principled - tax on the yield to capital, under just the conditions in which it is fair and appropriate to tax such yield. This gives a further reason to support a progressive cash-flow consumption tax, sounding in reasons familiar to income tax supporters. A consistent progressive cash-flow consumption tax will lower the burden of taxation when capital transactions (borrowing, saving, and investing) are used to smooth labor earnings within or between lifetimes (or taxpayers), and will increase the burden of taxation when capital transactions are used to enhance labor earnings within or between lifetimes (or taxpayers). Critical reflection based on a near century of experience reveals such a tax to give form to attractive normative ideals. The new understanding helps to show that the traditional and most common arguments for consumption taxation are not compelling. The best, most appealing case for a consumption tax does not rest on simple horizontal equity models, nor on claims about the economic, consequentialist importance of savings on an individual or an aggregate social level. Rather it is claims of fairness, in a social contractarian sense in the manner of John Rawls and other liberal theorists, that argue for a properly designed consumption tax - in part precisely because of the way such a tax sometimes but not all the times burdens capital and its yield, and in greater part because such a tax points the way towards greater, more meaningful progressivity in tax. The new understanding of tax yields important insights into pressingly practical matters of tax policy and design, and opens up an important window to critique contemporary trends in tax reform. The battle in tax policy should not be over income versus consumption taxation - as it has been for centuries - but rather over what kind of consumption tax to choose. Failure to address this question head-on has led tax policy to move, seemingly inexorably, towards the wrong choice, with the fate of progressive, redistributive taxation hanging in the balance.
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